Opinion
11019-19
05-03-2024
INTERMOUNTAIN ELECTRONICS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Ronald L. Buch, Judge
This case is set for trial at a Special Session scheduled to commence on June 17, 2024. On April 26, 2024, the petitioner filed fourteen (14) Motions for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established Pursuant to Rule 91(f) for fourteen separate sets of stipulations of fact (indices 86-99). From the content of those Motions, it appears that that petitioner filed the Motions protectively because of a then-impending deadline for filing such motions. The Court anticipates that the parties will be able to reach agreement with respect to those stipulations, in which case the parties may file a joint status report informing the Court that the parties agree that the Court can discharge this Order to Show Cause. In the event they are unable to reach agreement, however, it is
ORDERED that the petitioner's Motions for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established, filed April 26, 2024 (indices 86-99, inclusive) are granted. It is further
ORDERED that Commissioner shall, by May 16, 2024, file responses in compliance with the provisions of Rule 91(f), showing why facts and evidence set forth in the petitioner's proposed Stipulation of Facts attached as Exhibit A to petitioner's Motions (indices 86-99, inclusive) should not be deemed admitted for the purpose of this case.